Scenario: When performing a body piercing, the needle goes through the tissue at the piercing site and directly into the end of a sterile cork. The corks is then removed to allow for removal of the piercing forceps and insertion of the body jewelry. The cork is replaced on the top of the needle after removal from the tissue during the jewelry transfer
Question: Would removal and replacement of the cork onto the contaminated needle be considered recapping under paragraph (d)(2)(vii) of the standard?
Response: The Bloodborne Pathogens Standard requires the use of engineering and work practice controls [29 CFR 1910.1030 (d)(2)(0]. When an employee has exposure to a contaminated sharp and engineering controls (e.g., sharps with engineered safety features) are not available, hazard control is primarily gained through the implementation of work practices. In order to best protect an employee from an injury with a contaminated needle, minimal manipulation of the needle serves as means of control. Also, paragraph 29 CFR 1910.1030 (d)(4)(iii)(A)(1) requires the disposal of contaminated sharps in proper sharps containers immediately or as soon as feasible.
Furthermore, 29 CFR 1910.1030 (d)(2)(vii) states, (A)contaminated sharps shall not be bent, recapped or removed unless the employer can demonstrate that no alternative is.
Therefore, corking a contaminated needle would be allowed only if no alternative was feasible. As you explain, the cork itself is put in place in order to protect the employee performing the piercing from being stuck with the contaminated end of the piercing needle as the jewelry is pulled through the body. In this case, there may be no alternative and corking the contaminated needle may be necessary.
In an OSHA inspection the compliance officer would review the exposure control plan for written justification for the recapping supported by reliable evidence. Any permissible recapping must be performed by some method other than the traditional two-handed procedure (e.g., by means of a mechanical device or forceps).
